IRC 965 Transition Tax: Installment Election, Form 965-A, Acceleration, and LBI Audit Guide

The Tax Cuts and Jobs Act of 2017 (TCJA) imposed a one-time transition tax on U.S. shareholders of controlled foreign corporations (CFCs) and certain other foreign corporations under IRC 965, requiring the inclusion of accumulated post-1986 deferred foreign income in 2017 taxable income. Congress offered a safety valve: the 8-year installment election under IRC 965(h), allowing eligible taxpayers to spread payments over eight annual installments rather than pay the full liability with their 2017 return. For most calendar-year taxpayers, those installments have run their course. But for fiscal-year taxpayers still carrying a final installment, and for any taxpayer with an open IRC 965 position, the obligations that remain in 2026 are real and actively monitored: annual Form 965-A and Form 965-B filings, acceleration risk from corporate events, ongoing IRS LBI audit activity, and SOL issues for any year in which the IRC 965 income was not properly reported.

This guide is written for enrolled agents, CPAs, and tax attorneys advising clients who were subject to the IRC 965 transition tax. It covers the installment election mechanics, Form 965-A and Form 965-B reporting, the full range of acceleration events (with particular attention to the S-corp conversion trap), the LBI audit campaign, and SOL management, including the use of Form 872 consent agreements. All citations must be verified against IRC 965, the applicable IRS guidance, and current IRS.gov materials before reliance in any client matter.

Section 1: Background -- What IRC 965 Was and Who Was Subject

TCJA and the One-Time Transition Tax

TCJA (enacted December 2017) imposed a one-time "transition tax" under IRC 965 as part of the shift from a worldwide tax system to a participation-exemption system. The transition tax was the mechanism by which Congress collected U.S. tax on decades of accumulated earnings that U.S.-owned foreign corporations had deferred from U.S. taxation. Rather than let those earnings escape U.S. tax permanently under the new participation-exemption regime, Congress required U.S. shareholders to include the accumulated earnings in income for the 2017 taxable year, as if the amounts had been repatriated.

The inclusion under IRC 965 required U.S. shareholders (10% or more of voting stock, as defined in IRC 951(b)) who owned CFCs (as defined in IRC 957) to include their pro-rata share of the CFC's accumulated post-1986 deferred foreign income (ADFI) in 2017 taxable income. The ADFI was measured as of two testing dates: November 2, 2017, and December 31, 2017, with the higher of the two amounts used. Hedge all computation specifics for the ADFI to IRC 965 and the 2017 IRS instructions.

Who Was Subject to IRC 965

The transition tax applied broadly to U.S. shareholders of CFCs and to U.S. shareholders of "specified foreign corporations" (10%-or-more U.S.-owned foreign corporations that are not CFCs, as defined in IRC 965(e)(1)). The range of affected taxpayers included:

• C-corporations: Domestic C-corporations that directly or indirectly owned 10% or more of a CFC or specified foreign corporation were required to include the IRC 965 amount in 2017 income. C-corps were eligible to make the installment election under IRC 965(h).
• Individual U.S. shareholders: Individuals who directly or indirectly owned 10% or more of a CFC or specified foreign corporation were subject to the transition tax and could make the installment election. Individual shareholders file Form 965-A annually while the installment obligation remains outstanding.
• S-corporation shareholders: S-corporations that were U.S. shareholders of CFCs were subject to the transition tax at the shareholder level. S-corp shareholders could make a separate deferral election under IRC 965(i) (the S-corp deferral election), distinct from the installment election available to other taxpayers. The S-corp deferral election triggered its own acceleration rules. S-corporations file Form 965-B.
• Partners in partnerships holding CFC interests: Partners in partnerships that held CFCs included the IRC 965 amount at the individual partner level; the partnership itself was not directly subject to the transition tax. Partners were eligible to make the installment election based on their share of the transition tax liability.

The IRC 965(c) Deduction and Approximate Historical Effective Rates

IRC 965(c) provided a deduction that reduced the effective tax rate on IRC 965 inclusions. The deduction was larger for post-1986 accumulated foreign earnings held in cash or cash equivalents and smaller for earnings held in other property. The deduction was designed to produce approximate effective rates at the then-applicable 35% corporate statutory rate. Do NOT treat these as exact or current figures; they are approximate historical effective rates under prior law, at the then-applicable statutory rate. The IRC 965(c) deduction computation was performed on a 2017 basis; practitioners reviewing or litigating prior-year positions must use the 2017 figures and hedge all computation specifics to IRC 965(c), the applicable 2017 IRS instructions, and IRS.gov.

IRC 965 in 2026: A Look-Back Posture

As of 2026, IRC 965 is a look-back issue. The 2017 inclusion year is settled; the IRC 965 amount was reported (or should have been reported) on the 2017 return filed in 2018. What practitioners must manage in 2026 is the set of ongoing obligations that flow from the 2017 event:

• Installment payment obligations: For fiscal-year taxpayers whose installment schedules extend into 2026, the final installment remains a live obligation. Confirm the specific due date with reference to the taxpayer's taxable year-end, Form 965-A instructions, and IRS.gov.
• Acceleration risk: Any taxpayer with outstanding installments (including any fiscal-year taxpayer still on the installment schedule) faces acceleration risk if the triggering events under IRC 965(h)(3) occur. Acceleration risk does not sunset with the completion of the installment schedule; it exists for the duration of the outstanding obligation.
• Open LBI audits: IRS LBI has actively audited IRC 965 compliance since 2018. Taxpayers with open LBI inquiries, outstanding information document requests (IDRs), or signed Form 872 consent agreements remain in an active audit cycle.
• SOL monitoring: For taxpayers who signed Form 872 extensions, the extended period governs. For taxpayers who did not extend, the applicable SOL depends on whether the IRC 965 income was properly reported; the 6-year substantial omission rule (IRC 6501(e)(1)(A)) may apply if it was not. Hedge all SOL specifics to the taxpayer's specific filing history and current IRS guidance.

Section 2: The 8-Year Installment Election (IRC 965(h))

IRC 965(h) allowed eligible taxpayers to elect to pay the IRC 965 net tax liability in 8 equal annual installments rather than in a single lump sum with their 2017 return. The election was available to all U.S. shareholders who had a positive IRC 965 net tax liability for 2017. For most calendar-year taxpayers, the installment schedule has now run its course; the considerations that remain are for fiscal-year taxpayers still on the schedule, for any taxpayer managing an open audit, and for advising on the acceleration risk that persists until the liability is fully paid.

Installment Due Dates

The first installment was due with the taxpayer's 2017 income tax return (for calendar-year taxpayers, April 15, 2018, or with extension). Subsequent installments were due annually with each successive income tax return. For calendar-year taxpayers, the 8th and final installment was due April 15, 2025. At this point, most calendar-year installment elections have run their course.

For fiscal-year taxpayers whose 2017 taxable year ended on a date other than December 31, 2017, the installment due dates are keyed to the taxpayer's fiscal year-end, and the final installment may fall in 2025 or 2026, depending on the specific year-end. Practitioners with fiscal-year clients who made the installment election must confirm the specific installment schedule, including the due date of any remaining installments, with reference to the applicable year-end, the Form 965-A instructions, and IRS.gov. Do NOT assume the final installment is April 15, 2025 for fiscal-year taxpayers.

Irrevocability of the Election

The IRC 965(h) installment election was irrevocable. Once a taxpayer elected to pay the transition tax in installments, they were committed to the full 8-year schedule, subject only to the acceleration events described in Section 3 of this guide. A taxpayer who elected installments could not later revoke the election and pay the remaining balance on a different schedule (other than by paying off the balance in full, which would simply conclude the obligation ahead of schedule rather than being a revocation of the election).

Form 965-A and Form 965-B: Annual Filing While Installments Are Outstanding

Taxpayers who made the installment election are required to file Form 965-A (for individuals, partners, and S-corp shareholders) or Form 965-B (for S-corporations and REITs) annually with their income tax return until the liability is fully paid. These forms track the installment schedule, report the amount paid in the current year, and carry the remaining liability forward. Failure to file Form 965-A or Form 965-B is a compliance risk that LBI has actively flagged. Hedge all current form mechanics and filing instructions to the current IRS.gov instructions for Forms 965-A and 965-B.

Section 3: Acceleration Events -- When the Remaining Installments Come Due

IRC 965(h)(3) specifies triggering events that cause all remaining unpaid installments to become immediately due and payable. The acceleration provisions are not merely theoretical; they are live for any taxpayer whose installment schedule has not fully run, including fiscal-year taxpayers still carrying a final installment in 2026. Practitioners must advise clients on acceleration risk before recommending any corporate restructuring, liquidation, bankruptcy filing, or S-corp election for any entity that made the installment election.

Statutory Acceleration Events Under IRC 965(h)(3)

The following events trigger acceleration of remaining installments. Hedge the full scope of each trigger, including IRS administrative guidance on what constitutes a qualifying event, to IRC 965(h)(3) and current IRS guidance:

(a) Sale, Exchange, or Other Disposition of Substantially All Assets (IRC 965(h)(3)(A))

If the taxpayer sells, exchanges, or otherwise disposes of substantially all of its assets, the remaining installments become immediately due. The phrase "substantially all" is not given a bright-line definition in the statute; practitioners must refer to IRS guidance on what constitutes "substantially all" of the taxpayer's assets for purposes of IRC 965(h)(3). An asset sale that does not involve substantially all of the taxpayer's assets may not trigger acceleration, but the analysis is fact-specific. Hedge to current IRS guidance and IRC 965(h)(3)(A).

(b) Cessation of Business (IRC 965(h)(3)(A))

If the taxpayer ceases to engage in a trade or business, the remaining installments accelerate and become immediately due. This trigger is particularly relevant for corporate taxpayers that wind down operations prior to formal dissolution, as the cessation of business may occur before the legal dissolution of the entity. Hedge to IRC 965(h)(3)(A) and current IRS guidance.

(c) Liquidation or Dissolution (IRC 965(h)(3)(A))

Liquidation or dissolution of the taxpayer entity is an acceleration event under IRC 965(h)(3)(A). This applies to C-corporations, LLCs, and other entities that made the installment election. Practitioners handling corporate dissolution or liquidation transactions must determine whether any IRC 965 installment obligation remains outstanding and advise the client that the remaining balance will become immediately due upon dissolution.

(d) S-Corporation Election by a C-Corporation (IRC 965(h)(3)(B))

If a C-corporation that made the IRC 965(h) installment election subsequently elects S-corporation status under IRC 1362, the remaining installments accelerate and become immediately due. This provision is in IRC 965(h)(3)(B) and is one of the most significant planning traps for C-corporation clients considering an S-corp conversion at any point after 2017.

(e) Bankruptcy Filing (IRC 965(h)(3)(A))

If a taxpayer who made the installment election files for bankruptcy, the remaining installments accelerate under IRC 965(h)(3)(A). This can create complications in bankruptcy proceedings because the IRS holds an accelerated IRC 965 tax claim that becomes part of the bankruptcy estate's tax liabilities. The specifics of the bankruptcy acceleration rule, including whether it applies across all bankruptcy chapters or only certain chapters, and how the accelerated 965 claim interacts with the automatic stay and bankruptcy priority rules, are hedged to IRC 965(h)(3)(A), the applicable provisions of the Bankruptcy Code, and current IRS guidance. Practitioners handling bankruptcy matters for clients with outstanding IRC 965 installment obligations should address the acceleration issue explicitly with bankruptcy counsel.

(f) Other Triggering Events Specified by the Secretary

IRC 965(h)(3) also authorizes the Secretary of the Treasury to specify additional triggering events by regulation or guidance. Practitioners must confirm whether IRS has issued guidance on any administrative triggers beyond the statutory list before advising clients. Hedge to current IRS.gov announcements and applicable guidance under IRC 965(h)(3).

Section 4: Form 965-A and Form 965-B -- Annual Reporting Requirements

Taxpayers with an outstanding IRC 965 installment election or a deferred IRC 965 net tax liability under the S-corporation deferral election (IRC 965(i)) are required to file an annual report with each income tax return. The specific form depends on the taxpayer's entity type. Failure to file the required form is a compliance failure that LBI has identified as a priority enforcement issue.

Form 965-A: Individual Report of Net 965 Tax Liability

Form 965-A, "Individual Report of Net 965 Tax Liability," is required for:

• Individual taxpayers who made the IRC 965(h) installment election and who have a remaining installment balance outstanding.
• Partners in partnerships who have a deferred IRC 965 net tax liability from their partnership interest in a CFC, who made the installment election at the partner level.
• S-corporation shareholders who have a deferred IRC 965 net tax liability under the S-corporation deferral election (IRC 965(i)).

Form 965-A is filed annually with the taxpayer's Form 1040 until the liability is fully paid. The form tracks the original installment schedule, the amount paid in each prior year, and the remaining unpaid balance. Practitioners managing installment elections for individual clients must ensure Form 965-A is filed every year and that the amounts reconcile with the original election and any subsequent payments. Hedge all current form mechanics, line-by-line instructions, and any interim revisions to the current IRS.gov instructions for Form 965-A.

Form 965-B: Corporate and REIT Report

Form 965-B, "Corporate and Real Estate Investment Trust Report of Net 965 Tax Liability and Eligible Installment Requirements," is used by S-corporations and REITs. S-corporations file Form 965-B with Form 1120-S; REITs file with Form 1120-REIT. Form 965-B tracks the entity-level IRC 965 deferred liability that flows through to shareholders, and it reports whether the installment election or deferral election is in place at the entity level.

Practitioners who prepare or review S-corporation returns for entities subject to IRC 965 must ensure Form 965-B is included with the entity return annually and that the liability carried on the form reconciles with the entity's books and the shareholders' individual Form 965-A filings. Hedge all current Form 965-B mechanics and instructions to the current IRS.gov instructions for Form 965-B.

Section 5: LBI Audit Campaign and Statute of Limitations

IRS LBI Audit Campaign: Active Since 2018

IRS Large Business and International (LBI) division launched an active IRC 965 audit campaign in 2018, shortly after the first set of 2017 returns reflecting IRC 965 inclusions were filed. That campaign has continued and remains active in 2026. Hedge the specific scope and current status of the LBI IRC 965 campaign to current IRS.gov announcements and LBI publications; the specifics of which issues are under active examination may evolve, and practitioners should monitor IRS.gov for any updated LBI campaign guidance.

Based on published LBI audit campaign materials and IRS guidance through 2026, LBI's IRC 965 audit focus has included:

• Accuracy of the ADFI inclusion: Whether the taxpayer correctly computed its accumulated post-1986 deferred foreign income for each CFC and specified foreign corporation, using the correct measurement dates and the correct earnings and profits figures from Form 5471.
• IRC 965(c) deduction computation: Whether the participation deduction was correctly calculated, including the proper categorization of cash and cash equivalents vs. other property, and the allocation between the higher and lower deduction amounts. The 965(c) deduction was a complex, mechanical computation; errors are a common LBI audit finding.
• Timeliness and mechanics of the installment election: Whether the installment election was validly made with the 2017 return, whether the election was timely, and whether the installment amounts are correctly computed on Form 965-A or Form 965-B.
• Installment payment compliance: Whether the required installment payments have been made as required by the schedule and whether the amounts paid reconcile with the Form 965-A filings.
• FTC allocation to the 965 basket: Whether the foreign tax credit claimed for the 2017 year was correctly allocated to the IRC 965 transition tax basket, using the 2017 Form 1116 or Form 1118 mechanics then in effect, with no carryback or carryforward in the 965 basket.

Information Document Requests (IDRs) and Form 872 Consent Agreements

LBI has routinely issued information document requests (IDRs) to taxpayers under IRC 965 audit, requesting documentation of the ADFI computation, the IRC 965(c) deduction workpapers, the installment election paperwork, payment records, and the Form 5471 data underlying the computation. Responding to an IDR accurately and completely is critical; incomplete or inconsistent responses can extend the audit cycle and invite additional information requests.

IRS has also routinely requested that taxpayers sign Form 872 consent agreements to extend the period for assessment of IRC 965 taxes. The Form 872 extends the SOL (beyond the general 3-year period) for a specified period and for specified issues (IRC 965 matters). Practitioners must advise clients carefully on the risks and benefits of signing or declining a Form 872 request:

• If the taxpayer signs: The assessment period is extended for the duration specified in the Form 872. The taxpayer continues to have the ability to contest any proposed assessment, and signing does not admit liability. The extension gives IRS more time to complete the audit examination and may allow the taxpayer to provide additional documentation.
• If the taxpayer refuses: IRS may issue a statutory notice of deficiency (90-day letter) before the SOL expires, preserving IRS's right to assess. A notice of deficiency requires a response (petition to the U.S. Tax Court) within 90 days or the proposed deficiency becomes final. A refusal to extend the SOL is the taxpayer's right, but it can result in a forced assessment before the audit is complete.

Hedge the specifics of Form 872 consent agreements, including current IRS practice on scope limitations and what issues can be carved out, to current IRS practice and IRS.gov. For taxpayers who have already signed a Form 872 extension, confirm the extended period from the executed agreement and track the expiration date proactively.

Statute of Limitations for IRC 965 Assessments

The general 3-year SOL under IRC 6501(a) applies to IRC 965 matters. The SOL runs from the date the 2017 return was filed (or the due date, if later). For a calendar-year taxpayer who filed the 2017 return on April 15, 2018 (or with extension, by October 15, 2018), the general 3-year SOL would have expired in 2021 or 2022 unless extended by a Form 872 consent agreement. Many taxpayers who are still in an active LBI audit cycle signed Form 872 extensions that pushed the assessment period beyond the general 3-year window.

Section 6: Interaction with Foreign Tax Credits -- the 2017 IRC 965 Basket

U.S. shareholders who included IRC 965 amounts in 2017 taxable income were permitted to claim a foreign tax credit (FTC) under IRC 960 for the underlying foreign income taxes paid by the CFCs on the earnings that gave rise to the IRC 965 inclusion. The FTC available for IRC 965 income was subject to a separate "965 basket," with its own mechanics and significant limitations that distinguished it from the standard FTC baskets under IRC 904.

The 2017 IRC 965 FTC Basket: Key Mechanics

The IRC 965 transition tax basket was a one-time basket, fixed as of 2017. The key features of the 965 FTC basket (as enacted under TCJA and applicable to the 2017 return) included the following, hedged in full to the applicable 2017 IRC 960 and IRC 965 rules, the 2017 Form 1116 and Form 1118 instructions, and IRS.gov:

• Deemed-paid FTC under IRC 960: Corporate U.S. shareholders who had an IRC 965 inclusion could claim a deemed-paid FTC for the foreign taxes paid by the CFC on the earnings included. The deemed-paid FTC was computed under the IRC 960 mechanics then in effect (pre-2018 FTC rules). Hedge all computation mechanics to the 2017 Form 1118 instructions and IRS.gov.
• No carryback or carryforward in the 965 basket: Excess FTCs allocated to the 965 basket could not be carried back to a prior year or forward to a subsequent year. Unlike the passive and general FTC baskets under IRC 904(c), the 965 basket was a one-time basket with no carryover mechanism. Excess 965 FTCs were permanently lost.
• Separate basket computation: The 965 FTC was computed separately from the taxpayer's other FTC baskets (passive, general, and any other applicable basket for 2017). The income and taxes allocated to the 965 basket did not mix with the other baskets for limitation purposes.

Practitioners handling IRC 965 audit defense must use the 2017 FTC rules and the 2017 Form 1116 or Form 1118 mechanics. Hedge all FTC mechanics for the 965 basket to the applicable 2017 instructions, IRC 960 as it applied to the 2017 year, and IRS.gov. The 965 basket was specific to the 2017 transition tax inclusion; it does not recur.

Do Not Confuse the 965 Basket with the OBBBA NCTI FTC Basket

These rules are historical for purposes of 2017 return compliance and audit defense and should NOT be confused with the OBBBA NCTI FTC basket rules, which apply to tax years beginning after December 31, 2025. The OBBBA NCTI basket has a 90% FTC haircut (10% permanently non-creditable) and no carryover for excess NCTI FTCs, but it is a recurring annual basket that applies to ongoing CFC income from 2026 forward -- not a one-time transition tax mechanism. Using NCTI basket analysis for the IRC 965 audit, or applying 2017 965 basket rules to a 2026 NCTI position, would be a category error. Keep the two regimes clearly separated in any multi-year workpaper or client communication.

Frequently Asked Questions: IRC 965 Transition Tax for Practitioners

1. What is the IRC 965 transition tax and who was subject?

   IRC 965, enacted by TCJA in December 2017, imposed a one-time transition tax on U.S. shareholders (10% or more of voting power under IRC 951(b)) of CFCs and specified foreign corporations who had accumulated post-1986 deferred foreign income. The tax was owed for the 2017 taxable year. It applied to C-corporations, individual U.S. shareholders of CFCs, S-corporation shareholders (who could make a separate deferral election under IRC 965(i)), and partners in partnerships holding CFC interests (who included the IRC 965 amount at the partner level). The IRC 965(c) participation deduction reduced the effective tax rate on the inclusion; hedge computation specifics to IRC 965(c) and the 2017 IRS instructions.

2. What is the 8-year installment election and when was the final installment?

   IRC 965(h) permitted taxpayers to elect to pay the transition tax in 8 equal annual installments instead of in full with their 2017 return. For calendar-year taxpayers, the 8th and final installment was due April 15, 2025. For fiscal-year taxpayers, the installment due dates depend on the taxpayer's taxable year-end, and the final installment may fall in 2025 or 2026. Confirm installment due dates with reference to the taxpayer's specific fact pattern, the Form 965-A instructions, and IRS.gov. Do not assume the April 15, 2025 date applies to fiscal-year clients.

3. What events accelerate the remaining IRC 965 installments?

   Under IRC 965(h)(3), the remaining unpaid installments become immediately due if the taxpayer liquidates or dissolves, sells substantially all its assets, ceases to engage in a trade or business, files for bankruptcy, or (for C-corporations) elects S-corporation status under IRC 1362. The Secretary of the Treasury may also specify additional triggering events by guidance. Practitioners must advise clients on acceleration risk before recommending any corporate restructuring, liquidation, bankruptcy filing, or S-corp election for any entity that made the installment election. Hedge the full scope of each triggering event to IRC 965(h)(3) and current IRS guidance.

4. Can a C-corporation elect S-corporation status without triggering acceleration of the IRC 965 installments?

   No. Under IRC 965(h)(3)(B), if a C-corporation that made the installment election subsequently elects S-corporation status under IRC 1362, the remaining installments accelerate and become immediately due. This is a significant trap in corporate conversions; a C-corp with an outstanding IRC 965 installment obligation must pay off the remaining balance before converting to S-corp status, or the conversion will trigger immediate payment of all remaining installments. Practitioners must check for an outstanding IRC 965 installment obligation as a threshold step before recommending or implementing an S-corp election for any former C-corp client that was subject to the transition tax. Cite IRC 965(h)(3)(B) and confirm with current IRS guidance.

5. Does IRS still audit IRC 965 compliance in 2026?

   Yes. IRS Large Business and International (LBI) division has maintained an active IRC 965 audit campaign since 2018 and continues to audit compliance in 2026. LBI has focused on the accuracy of the ADFI inclusion, the IRC 965(c) deduction computation, the timeliness and mechanics of the installment election, installment payment compliance, the annual Form 965-A and Form 965-B filings, and the FTC allocated to the 965 basket on the 2017 return. Taxpayers with open LBI inquiries, outstanding IDRs, or signed Form 872 consent agreements remain in an active audit cycle and should ensure all required forms are filed and installment payments are current. Hedge any specific LBI campaign details to current IRS.gov announcements and LBI publications.

6. What is the statute of limitations for IRC 965 assessments?

   The general 3-year SOL under IRC 6501(a) applies to IRC 965 matters; the 3-year period runs from the date the 2017 return was filed (or the due date, if later). However, if the IRC 965 income was substantially omitted from the 2017 return -- meaning the omission exceeded 25% of gross income -- the 6-year SOL under IRC 6501(e)(1)(A) may apply instead. Additionally, many IRC 965 taxpayers signed Form 872 consent agreements at IRS's request, extending the assessment period beyond the general 3-year window. For taxpayers who signed Form 872 extensions, the extended period specified in the executed agreement controls. Hedge all SOL determinations to IRC 6501, the taxpayer's specific filing history, any executed Form 872 agreements, and current IRS guidance.

7. What is Form 965-A and when must it be filed?

   Form 965-A, "Individual Report of Net 965 Tax Liability," must be filed annually by individual taxpayers, partners, and S-corporation shareholders who made the installment election or have a deferred IRC 965 net tax liability under the S-corporation deferral election (IRC 965(i)). It is attached to the taxpayer's income tax return (Form 1040) each year until the liability is fully paid. The form tracks the original installment schedule, amounts paid in prior years, and the remaining balance. S-corporations and REITs use Form 965-B instead. IRS LBI has flagged failures to file Form 965-A and Form 965-B as a specific compliance priority in its IRC 965 audit campaign. Hedge all current Form 965-A and Form 965-B mechanics and instructions to the current IRS.gov instructions for those forms.

Disclaimer and Verification Notice

This guide is for informational purposes only and does not constitute legal, tax, or accounting advice. All statutory citations (including IRC 965, IRC 965(h), IRC 965(h)(3), IRC 965(c), IRC 965(i), IRC 951(b), IRC 957, IRC 960, IRC 6501(a), IRC 6501(e)(1)(A), and IRC 1362), regulatory references, IRS guidance, and computation mechanics must be verified against the enacted IRC 965, current IRS.gov guidance, current Form 965-A instructions, current Form 965-B instructions, and any LBI guidance or revenue procedures applicable to IRC 965 matters, before reliance in any specific client matter. Installment due dates, acceleration triggering event specifics, SOL determinations, and Form 872 mechanics are all fact-specific and depend on the individual taxpayer's filing history, entity type, and applicable IRS guidance. Do not rely on the general summaries in this guide as a substitute for analysis of the taxpayer's specific facts.

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